Introduction:
The Supreme Court of India, in Piyush Shyamdasani v. State of Uttar Pradesh (2026 LiveLaw (SC) 699), delivered an important judgment on the evidentiary value of circumstantial evidence, particularly mobile phone call records, in establishing motive in a murder case. A Bench comprising Justice Dipankar Datta and Justice Satish Chandra Sharma upheld the conviction of the husband and other co-accused for the murder of his wife while refusing to interfere with the acquittal of the husband’s alleged lover.
The case arose out of a gruesome incident that occurred in July 2014. According to the prosecution, the husband conspired with several persons to eliminate his wife because she opposed his alleged extramarital relationship. The murder was allegedly executed under the guise of a dinner outing. While returning home, the couple was intercepted by assailants who dragged the husband out of the vehicle, allegedly assaulted him, and abducted his wife along with the car. Later, the abandoned vehicle was recovered with the wife’s body inside.
The prosecution asserted that the incident was carefully planned. The husband allegedly remained in continuous contact with the co-accused through mobile phones, including a fake SIM card, before and during the commission of the offence. The trial court convicted all accused under Sections 302, 364, 201, 203, 404 and 120-B of the Indian Penal Code. The High Court affirmed the convictions but acquitted the alleged lover due to insufficient evidence linking her to the conspiracy. Aggrieved by the conviction, the husband and other accused approached the Supreme Court, while the State challenged the acquittal of the alleged lover.
Arguments of the Parties:
The appellants contended that the prosecution had failed to establish a complete chain of circumstantial evidence connecting them with the murder. They argued that the conviction rested largely upon suspicion, assumptions and call detail records, none of which conclusively proved their involvement. According to them, mere telephonic communication between individuals could not establish participation in a criminal conspiracy. They also questioned the recoveries made during investigation and submitted that the evidence lacked reliability and independent corroboration.
The husband further argued that the prosecution failed to prove that he had actively participated in the murder. It was submitted that he himself was allegedly assaulted during the occurrence and could not be treated as one of the perpetrators merely because of his alleged relationship with another woman. The appellants also challenged the application of Section 34 IPC, contending that the prosecution itself alleged involvement of more than five persons and therefore the provision had been wrongly invoked.
With respect to the acquitted co-accused, the State argued that the unusually high number of phone calls exchanged between her and the husband, coupled with the marital discord between the deceased and the husband, established her participation in the conspiracy. According to the prosecution, the deceased had objected to the illicit relationship, thereby providing a strong motive for both of them to eliminate her.
The State also relied upon the recoveries of blood-stained articles, jewellery belonging to the deceased, clothes worn by the accused, mobile phones used during the conspiracy, CCTV footage and purchase invoices showing procurement of the murder weapon before the incident. It argued that these circumstances, when read together, formed an unbroken chain pointing only towards the guilt of the convicted accused. The prosecution further submitted that the accused failed to explain several incriminating circumstances that were within their exclusive knowledge, thereby attracting an adverse inference under Section 106 of the Indian Evidence Act.
Court’s Judgment:
The Supreme Court dismissed the appeals filed by the convicted accused and affirmed their conviction. The Court held that the prosecution had successfully established a complete chain of circumstantial evidence leaving no reasonable doubt regarding their involvement in the murder.
The Bench found that the call detail records demonstrated continuous communication among the accused before and around the time of the offence. The evidence sufficiently established that the accused were in regular contact through specific mobile numbers, irrespective of the names in which those numbers were officially registered. The Court held that these records were relevant in proving coordination among the conspirators and formed an important circumstance in the overall chain of evidence.
The Court also accepted the prosecution’s case regarding motive. It observed that the deceased had opposed the husband’s alleged extramarital relationship and that the marriage had been experiencing serious discord. In these circumstances, the Court concluded that the deceased had become an obstacle to the continuation of that relationship. The unusually frequent communication between the husband and the alleged lover strengthened the inference that such a relationship existed. However, the Court clarified that while these calls established motive, they did not automatically prove participation in the criminal conspiracy.
The Bench emphasised that motive alone cannot sustain a conviction, but where it is supported by a complete chain of surrounding circumstances, it becomes a significant factor. The prosecution had established several independent circumstances, including recoveries pursuant to disclosure statements, seizure of blood-stained articles, recovery of jewellery belonging to the deceased, the mobile phones used during the conspiracy and CCTV footage corroborating the purchase of the murder weapon before the crime. These circumstances substantially reinforced the prosecution’s case.
A significant factor considered by the Court was the conduct of the husband immediately after the incident. Although he claimed to have been assaulted by the assailants, medical evidence revealed no corresponding injuries. The Court found it highly unnatural that a husband whose wife had allegedly been abducted would leave the hospital before undergoing proper medical examination and delay informing the police for nearly an hour. According to the Bench, such conduct was inconsistent with ordinary human behaviour and indicated an attempt to facilitate the completion of the crime before police intervention.
The Court further invoked Section 106 of the Indian Evidence Act. It observed that once the prosecution had established strong incriminating circumstances, the burden shifted to the accused to explain facts that were especially within their personal knowledge. Instead of providing any satisfactory explanation regarding their communications, movements and connections, the accused merely denied the allegations. Such failure entitled the Court to draw an adverse inference against them.
On the issue of Section 34 IPC, the Supreme Court rejected the contention that it had been wrongly invoked merely because several persons were involved. The Court clarified that common intention can exist even if one accused is not physically present at the exact place of occurrence. The husband’s planning, coordination and active participation from behind the scenes were sufficient to attract liability under Section 34 read with the substantive offences.
However, the Court declined to interfere with the acquittal of the alleged lover. It held that although the unusually high number of calls exchanged between her and the husband reasonably indicated the existence of a close relationship, there was no evidence connecting her with the remaining accused or proving that she participated in planning or executing the murder. There was a clear break in the chain of circumstantial evidence insofar as she was concerned. Criminal conspiracy requires proof of agreement to commit the offence, and such agreement could not be inferred solely from frequent telephone conversations or the existence of an illicit relationship.
The Supreme Court therefore upheld the conviction of the husband and the remaining convicted accused while maintaining the acquittal of the alleged lover. The judgment reiterates that in cases based on circumstantial evidence, courts must examine whether every circumstance forms an unbroken chain pointing exclusively towards guilt. It also clarifies that frequent telephonic communication may constitute a relevant circumstance for establishing motive but cannot, without additional evidence, be treated as proof of participation in a criminal conspiracy.